Utah’s 2026 regulatory landscape brings notable changes across air permitting, PM2.5 and ozone planning, enforcement priorities, and emerging requirements for refrigerants, PFAS, and greenhouse gas programs. These developments create a more dynamic compliance environment, and facilities should be prepared to adjust their permitting, reporting, and operational strategies accordingly.
Utah Regulatory Hot Topics
New Permit‑by‑Rule Regulations Simplify Approvals for Small Sources
Utah implemented two new Permit‑by‑Rule (PBR) regulations, R307‑431 and R307‑432, to reduce permitting burden for certain equipment and source categories. These rules exempt qualifying sources from obtaining an Approval Order when specific conditions are met. Examples of equipment and activities now eligible for exemptions include:
- Small natural‑gas boilers and heaters
- Emergency heating equipment
- Certain fuel storage tanks and degreasing operations
- Well sites
- Gasoline dispensing facilities
- Dry cleaners, automotive refinishing, and portable aggregate plants
Major sources and large minor sources remain subject to traditional permitting, but small minor sources may now subtract exempt equipment when calculating potential‑to‑emit and potentially qualify for Utah’s Small Source Exemption. This represents an opportunity for administrative relief and simplified compliance management.
PM2.5 Attainment Redesignations Introduce New Modeling Requirements
Salt Lake City and Provo have been redesignated to attainment for the 2006 24‑hour PM2.5 standard. Following this change, Utah now requires both 24‑hour and annual PM2.5 dispersion modeling for new or modified projects that exceed modeling thresholds. Facilities planning projects in these areas should anticipate:
- Additional air‑modeling analysis
- Longer permitting timelines
- More detailed coordination with the Utah Division of Air Quality
While redesignation reflects successful air‑quality improvements, modeling requirements are now more rigorous than before.
Ozone Nonattainment Areas: Reclassifications Stayed, but Only Temporarily?
Two major ozone areas in Utah were recently reclassified:
- Northern Wasatch Front – Reclassified from Moderate to Serious but currently subject to a judicial stay, temporarily halting more stringent requirements such as lower major‑source thresholds and expanded RACT obligations.
- Uinta Basin – Reclassified from Marginal to Moderate but also stayed pending EPA reconsideration.
These stays pause implementation but do not resolve the underlying nonattainment issues. Facilities should be prepared for the possibility that stricter obligations could return once the stays are lifted.
NSPS Subparts Kc and KKKKa: Active Requirements for Tanks and Turbines
Two federal standards now affect many Utah facilities:
- NSPS Subpart Kc applies to storage vessels constructed or modified after October 2023. Requirements include applicability notifications, internal floating‑roof LEL monitoring, controlled degassing procedures, alarm requirements, and semiannual reporting.
- NSPS Subpart KKKKa applies to stationary combustion turbines built or modified after December 2024. It introduces new subcategories, updated NOₓ standards, provisions for temporary turbines, and updated SO₂ compliance options.
These rules are active and should be reviewed for applicability to current or planned projects.
Utah Reporting Updates and Reminders
Tier II Reporting (March 1)
Utah requires Tier II submissions through Tier2Submit, with additional required submissions to local LEPCs and fire departments. OSHA’s 2024 Hazard Communication revisions expand hazard categories from 24 to 114, making updated SDSs essential for accurate reporting.
Common issues include mismatched hazards, missing maximum/average quantity calculations, overlooking lead‑acid batteries with low reporting thresholds.
UDAQ Emissions Inventories
Utah’s next triennial emissions inventory is due April 15, 2027, covering actual 2026 emissions. Recent rule updates require:
- Reporting of all hazardous air pollutants (no thresholds)
- Annual reporting of SO2 directly in SLEIS for large emitting sources
- Anticipation of future mobile‑source reporting requirements
This inventory supports SIP planning, rulemaking, and emissions fee development.
Refrigerant Management Reporting
Annual chronic‑leaker reports are required for large appliances leaking 125% or more of full charge within a year. For ozone‑depleting substances, appliances with 50 lbs. or more trigger reporting. Beginning in 2027, this reporting expands to include HFC systems 15 lbs. or larger with global‑warming‑potential above 53.
TRI Reporting
Facilities must continue annual threshold analyses and submit TRI reports by July 1. PFAS tracking requirements continue to expand, increasing the need for early data gathering.
Federal Updates
EPA Enforcement Declines and Focus Shifts
EPA enforcement activity has dropped significantly in the past year, with only a single compliance advisory released in 2025 and historically low levels of litigation. Current priorities focus on imminent public health risks, illegal HFC imports, and select waste‑related concerns. Enforcement tied to methane emissions, environmental justice, or expanded oversight has been deemphasized by the current EPA administration.
CWA Facility Response Plan Rule
Compliance deadlines for the new Hazardous Substance Facility Response Plan rule are expected to be pushed back, and EPA may revise several core definitions and thresholds as part of that process. Facilities should keep preliminary screening records up to date and monitor developments closely.
Regional Haze Planning
Work on the Regional Haze Rule is evolving, as EPA reconsiders several elements of the program and has already issued partial disapprovals for some state plans. Utah is preparing to submit revised SIP materials in 2026 to address visibility modeling and reasonable‑progress concerns.
PM2.5 National Standard Uncertainty
EPA has signaled its intent to rescind the 2024 lowering of the annual PM2.5 NAAQS from 12 to 9 µg/m³, though the 9 µg/m³ standard remains in effect while the agency completes rulemaking. New modeling constraints and pending nonattainment designations will continue impacting permitting until EPA finalizes changes.
GHG Reporting and the Endangerment Finding Under Review
The federal GHG Reporting Program may be significantly scaled back. A 2025 proposal would eliminate reporting for nearly all source categories after reporting year 2024 and suspend Subpart W reporting until 2034. Additionally, EPA announced on February 12, 2026, a final rule that rescinds the 2009 GHG Endangerment Finding, a move that fundamentally affects greenhouse gas regulation nationwide. Litigation is virtually guaranteed on this action.
PFAS Oversight Continues to Expand
While many federal programs face rollback, PFAS or “forever chemicals” regulation remains an area of ongoing development. TRI reporting thresholds now cover more than 200 PFAS, CERCLA continues to classify PFOA and PFOS as hazardous substances, and stormwater and wastewater programs are incorporating new PFAS monitoring requirements. Drinking water rules have narrowed their scope but extended compliance timelines, reducing immediate burdens while maintaining long‑term expectations.
HFC Management Rule Now in Effect
Under 40 CFR Part 84, hydrofluorocarbons (HFCs) and refrigerant substitutes with global warming potential above 53 are now regulated with a January 1, 2026, effective date for most requirements. The rule is similar to the requirements for ODS appliances under 40 CFR Part 82, Subpart F, with some differences, including a lower capacity threshold of 15 pounds for leak repair requirements. For more information on refrigerant management, see our Refrigerant Management Services (ODS and HFC) webpage.
Key Takeaways
Utah’s 2026 regulatory landscape continues to shift, and facilities will need to stay flexible as both state and federal programs evolve. New Permit‑by‑Rule options may ease permitting for some smaller sources, while PM2.5 redesignation in Salt Lake City and Provo brings tighter modeling expectations. Ozone reclassification stays offer only temporary breathing room, and federal updates affecting tanks, turbines, refrigerants, PFAS, and GHG programs add to the complexity. With significant reporting requirements still in place, organizing data early will go a long way toward keeping compliance on track.
Resources
- To stay current on our Utah reporting requirements, download a copy of the Utah annual reporting compliance calendar.
- For a copy of our slide deck from our recent presentation on 2026 Annual Compliance Reporting and Hot Topics in Utah reach out to Zoe Stone.
- For support with your upcoming reporting requirements or questions on regulatory changes in Utah, reach out to Trinity’s Salt Lake City office.
